-BEFGRE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
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Docket No. MC98-1
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OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
WITNESS: BETH B. ROTHSCHILD
(OCA/USPS-T4-37-45)
(November 2, 1998)
Pursuant to sections 25 and 26 of the Rules of Practice of the Postal Rate
Commission,
the Office of the Consumer
requests for production
OCA/USPS-Tl-1-7
incorporated
of documents.
Advocate
Instructions
hereby submits interrogatories
included with OCA interrogatories
to witness Lee Garvey, dated July 21, 1998, are hereby
by reference.
Respectfully
and
submitted,
Gail Willette
Acting Director
Office of the Consumer
Emmett Rand Costich
Acting Assistant Director
Advocate
Docket No. MC98-1
OCA/USPS-T4-37.
contribution
Please refer to NetPost’s Commercial
margin, for “Next-Day
end of Attachment
a.
2
Prices, at the 25 percent
Delivery” shown on the rate card that appears at the
E in USPS-LR-2/MC98-1.
Please confirm that there is no price per piece associated
Black & White or Spot color, Simplex pieces.
with 1-2 page, 11x17
If you do not confirm, please
explain and provide the price per piece.
b.
Please confirm that l-2 page, 11x17 Black &White
was not offered as an option to survey respondents.
or Spot color, Simplex pieces
If you do not confirm,
please explain.
C.
Please confirm that you have estimated
no Mailing Online volume for l-2 page,
11x17 Black & White or Spot Color, Simplex pieces,
If you do not confirm,
please explain.
OCAIUSPS-T4-38.
contribution
Please refer to NetPost’s Commercial
Prices, at the 25 percent
margin, shown on the rate cards that appear at the end of Attachment
E in
USPS-LR-2/MC98-I.
a.
In the row labeled “More than 15 pages” on the “Next-Day
“Standard
“Applicable
(Two-To-Five
Day) Delivery” rate cards, please confirm that the
postage rate + per page production
cost” represents
average price per piece for Simplex and Duplex 85x11,
Black & White and Spot color.
b.
(Two-To-Five
85x14,
a weighted
and 11x17
If you do not confirm, please explain.
In the row labeled “More than 15 pages” on the “Next-Day
“Standard
Delivery” and
Delivery” and
Day) Delivery” rate cards, please provide the “Applicable
Docket No. MC98-1
3
postage rate + per page production
cost” for Simplex and Duplex 85x11,
85x14,
and 11x17 Black & White and Spot color.
OCAAJSPS-T4-39.
contribution
margin, for “Next-Day
end of Attachment
a.
Please refer to NetPost’s Commercial
Prices, at the 25 percent
Delivery” shown on the rate cards that appear at the
E in USPS-LR-2/MC98-1.
Please confirm that the total volume is 91,744,857
(295,665,025
l
.3103).
If you
do not confirm, please explain and provide the correct figure.
b.
Please confirm that volume for Simplex pieces is 44,083,404
.4805).
C.
d.
*
If you do not confirm, please explain and provide the correct figure.
Please confirm that volume for Duplex pieces is 47,661,453
.5195).
(91,744,857
(91,744,857
*
If you do not confirm, please explain and provide the correct figure.
Please confirm that the volume for l-2 page Simplex pieces is 29,895,946
(44,083,404
l
(200,490,454
/295,635,459)).
If you do not confirm, please
explain and provide the correct figure.
e.
For l-2 page Simplex pieces, please provide the volume associated
price per piece of $0.36 for 8.5x1 1 and 8.5x14, respectively,
and $0.46 for 8.5x1 1 and 8.5x14. respectively,
f.
with the
for Black & White,
for Spot color.
Please confirm that the volume for “More than 15 pages,” Simplex pieces is
3,108,191
((44,083,404
* (20,844,3841295,635.459)).
please explain and provide the correct figure.
If you do not confirm,
Docket No. MC98-1
9.
4
For “More than 15 pages” Simplex pieces, please provide the volume for 8.5x1 1,
8.5x14 and 11x17 for Black & White, and for 8.5x1 1, 8.5x14 and 11x17 for Spot
color.
h.
Please confirm that the volume for “More than 15 pages,” Duplex pieces is
3,360,469
((47,661,453
* (20,844,384
/295,635,459)).
If you do not confirm,
please explain and provide the correct figure.
i.
For “More than 15 pages” Duplex pieces, please provide the volume for 8.5x1 1,
8.5x14 and 11x17 for Black & White, and for 8.5x1 1, 8.5x14 and 11x17 for Spot
color.
OCA/USPS-T4-40.
contribution
Please refer to NetPost’s
margin, for “Standard
(Two-To-Five
that appear at the end of Attachment
a.
Commercial
Prices, at the 25 percent
Day) Delivery” shown on the rate cards
E in USPS-LR-2/MC98-I.
Please confirm that the total volume is 203,920,168
(295665,025
* .6897).
If
you do not confirm, please explain and provide the correct figure.
b.
Please confirm that volume for Simplex pieces is 97,983,641
.4805).
C.
d.
l
If you do not confirm, please explain and provide the correct figure.
Please confirm that volume for Duplex pieces is 105,936,527
,5195).
(203,920,168
(203,920,168
l
If you do not confirm, please explain and provide the correct figure.
Please confirm that the volume for “More than 15 pages,” Simplex pieces is
6,908,538
((97,983,641
l
(20,844,384
/295,635,459)):
please explain and provide the correct figure.
If you do not confirm,
Docket No. MC98-1
e.
5
For “More than 15 pages” Simplex pieces, please provide the volume for 8.5x1 1,
85x14
and 11x17 for Black 8 White, and for 8.5x11, 8.5x14 and 11x17 for Spot
color.
f.
Please confirm that the volume for “More than 15 pages,” Duplex pieces is
7,469,272
((105,936,527
* (20,844,384
/295,635,459)).
If you do not confirm,
please explain and provide the correct figure.
9.
For “More than 15 pages” Duplex pieces, please provide the volume for 8.5x1 1,
85x14
and 11x17 for Black 8 White, and for 85x11,
8.5x14 and 11x17 for Spot
color.
OCA/USPS-T4-41.
contribution
Please refer to NetPost’s Commercial
margin, shown on the rate cards that appear at the end of Attachment
USPS-LR-2/MC98-1,
calculates
a.
Prices, at the 25 percent
and USPS-T-5,
E in
Exhibit D, at 1. In Exhibit D, Witness Plunkett
Mailing Online volume for l-2 page pieces on 11x17 paper of 24,680,375.
Please confirm that the figure, 24,680,375,
assumes there is Next Day Mailing
Online volume for l-2 page, 11x17 Black & White, and 11x17 Spot color,
Simplex pieces.
b.
If you do not confirm, please explain.
Please confirm that the figure, 24,680,375,
overstates
the volume of l-2 page
pieces on 11x17 paper by the amount of Next Day volume assumed for 1-2
page, 11x17 Black & White, and 11x17 Spot color, Simplex pieces.
If you do not
confirm, please explain.
C.
Please provide the correct Mailing Online volume for l-2 page pieces on 11x17
paper.
Docket No. MC98-1
OCA/USPS-T4-42.
a.
6
Please refer to Table 15 your testimony
at page 34.
Please provide the average revenue per piece associated
with the total “Year 1”
volume of 295,665.
b.
Please provide the average revenue per piece associated
with the First-Class
“Year 1” volume of 91,745.
C.
Please provide the average revenue per piece associated
with the Standard
“Year 1” volume of 203,920.
OCA/USPS-T4-43.
a.
Please refer to Table 16 your testimony
at page 35.
Please provide the average revenue per piece associated
with the total “Year 1”
volume of 204,195.
b.
Please provide the average revenue per piece associated
with the First-Class
“Year 1” volume of 24,034.
C.
Please provide the average revenue per piece associated
with the Standard
“Year 1” volume of 180,161.
OCAWSPS-T4-44.
Please provide volume estimates for the 1999-2003
time period
based upon the rates and premailing fees in effect during the market test.
OCAAJSPST4-45.
Please provide volume estimates for the 1999-2003
time period
based upon the rates and premailing fees expected to be in effect during the
experimental
phase.
Docket No. MC98-1
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing
participants
of record in this proceeding
practice
in accordance
upon all
with section 12 of the rules of
&i/vPQxb
w
Emmett Rand Costich
Attorney
Washington, D.C. 20268-0001
November 2, 1998
document